JTH Tax LLC v. Cortorreal

District Court, E.D. Virginia·Decided August 23, 2024·No. 2:23-cv-00355·Unknown

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Norfolk Division JTH TAX LLC, d/b/a LIBERTY TAX SERVICE, Plaintiffs, v. Civil Action No. 2:23-cv-0355 LOWENSKY CORTORREAL; RAMON CORTORREAL; and THE EAGLES TEAM LLC, Defendants.

MEMORANDUM OPINION AND ORDER Before the Court are three Motions to Dismiss the Amended Complaint pursuant to the Federal Rules of Civil Procedure (“FRCP”) 12(b)(1) and 12(b)(6) filed by Ramon Cortorreal, ECF No. 42 (“R. Cortorreal Mot.”), Lowensky Cortorreal, ECF No. 43 (“L. Cortorreal Mot.”), and The Eagles Team LLC (collectively, “Defendants”). ECF No. 44 (“The Eagles Team Mot.”). Defendants each filed a Memorandum in Support of the Motion. ECF Nos. 45, 46, 47. JTH Tax, Liberty Tax Service (“Liberty” or “Plaintiff’) filed a consolidated response to Defendants’ Motions. ECF No. 48 (“PI.’s Resp.”). The Court has considered the parties’ memoranda and this matter is ripe for judicial determination. For the reasons stated herein, Defendants’ Motions to Dismiss are GRANTED IN PART and DENIED IN PART. I. FACTUAL AND PROCEDURAL HISTORY On February 17, 2023, Plaintiff filed a Complaint alleging unlawful competition and breach of the franchise agreements. ECF No. 1. On March 29, 2023, Defendants filed three motions to dismiss for improper venue and lack of subject matter jurisdiction under the Defend Trade

Secrets Act of 2016, 18 U.S.C. § 1836 (“DTSA”). ECF Nos. 10, 11, 12. On July 20, 2023, Judge Pittman of the United States District Court for the Northern District of Texas issued an Opinion and Order granting in part Defendants’ motions to dismiss for improper venue and transferred this case to this Court. ECF No. 24.’ On March 1, 2024, the Court granted Defendants’ motions to dismiss for lack of subject matter jurisdiction under the DTSA and granted Plaintiff leave to amend. ECF No. 39. Relevant to Defendants’ Motions to Dismiss and stated in the light most favorable to Plaintiff, the following alleged facts are drawn from the Amended Complaint and attachments thereto. Liberty Tax Service On March 18, 2024, Liberty, a Delaware limited liability company with its principal place of business in Hurst, Texas, filed an Amended Complaint against Defendants, who all reside in Texas. ECF No. 40 (Am. Compl.”). Liberty is a franchisor of Liberty Tax Service, an income tax preparation service whose centers are located throughout the United States. /d. 17. Liberty generates 90% of its annual revenue during the tax season, which runs from January to April each year. /d, 4 18. “Liberty has invested substantial time and money developing and promoting the distinctive and well-known Liberty Tax Service system, which sells income tax preparation services and products to the public under Liberty’s trademarks.” /d. | 19. Liberty grants a limited license to its franchisees “to identify as Liberty franchisees and use Liberty’s highly guarded and valuable confidential information and trade secrets.” /d. § 20. This includes “customer lists, customer files, private customer information (such as names, phone numbers, social security numbers and other tax return and financial information), operational methods, promotional plans, marketing strategies, pricing structures, business strategies, training material and other proprietary

1 In the Opinion and Order, Judge Pittman exercised discretion not to resolve the issue of subject matter jurisdiction in the interest of justice. ECF No. 24.

trade secrets and know-how, including its Operations Manual . . . .” (collectively, “Trade Secrets” and “Confidential Information”). Jd. Additionally, “Liberty’s franchisees pay monthly [royalties] and advertising fees and agree to various in-term and post-termination obligations.” /d. 21. Lowensky Cortorreal’s Franchise Agreements Lowensky Cortorreal (“L. Cortorreal”) is a former Liberty franchisee. /d. ] 22. Around June 28, 2019, Liberty and L. Cortorreal entered into two franchise agreements for franchise territories TX016 (“TX016 Agreement”) and TX728 (“TX728 Agreement”) (collectively, the “Franchise Agreements”). Jd. J] 23-24. Each franchise agreement carried a five-year term. □□□ | 25. Allegedly, “L. Cortorreal personally guaranteed the Franchise Agreements.” Jd. 26. L. Cortorreal operated tax preparation offices at 2124 Holly Hall Street in Houston, Texas, and 15881 FM 529 Road, Suite C, in Houston, Texas. /d. 27. According to the Franchise Agreements, L. Cortorreal had “a license to use Liberty’s Confidential Information and to identify as a Liberty franchisee.” Jd. 28. “Liberty also provided L. Cortorreal with training in its operation, marketing, advertising, sales, and business systems.” /d. Liberty also provided L. Cortorreal with a copy of its “confidential operating, marketing, and advertising materials, including its proprietary Operations Manual, which contains Liberty’s operational methods, promotional plans, marketing strategies, pricing structures, business strategies, training material and other proprietary trade secrets and know-how, which are not available to the public or to anyone who is not part of [the] business.” /d. Under Section 1 of the Franchise Agreements, L. Cortorreal had a “license to trade on Liberty’s Confidential Information, proprietary tax system, trade namesf,] and trademarks.” □□□ 29. L. Cortorreal agreed to pay Liberty monthly royalties and advertising fees in the amount of 19% of gross receipts and pay minimum royalties in the event of early, unilateral termination of

the Franchise Agreements. /d. {§ 30-31. Interest on all amounts L. Cortorreal owes Liberty compounds daily at a rate of 12% per annum. /d. | 32. According to the Franchise Agreements, L. Cortorreal agreed to “return Liberty’s customer lists and Operations Manual and all updates, and adhere to the Franchise Agreements’ post-termination non-competition and non-solicitation covenants set forth in Sections 10(b) and 10(d).” /d. | 33. Allegedly, L. Cortorreal agreed to not compete with Liberty within twenty-five miles of the boundaries of the franchise territories for two years following termination. /d. On January 23, 2022, Liberty terminated the Franchise Agreements and L. Cortorreal never returned Liberty’s confidential Operations Manual. /d. Under Section 9 of the Franchise Agreements, L. Cortorreal agreed to: “(1) return Liberty’s confidential Operations Manual; (2) cease using Liberty’s Confidential Information; (3) pay all amounts due and owing to Liberty; and (4) adhere to all post-termination non-competition and non-solicitation covenants” immediately upon termination. /d. { 34. According to Section 10(a) of the Franchise Agreements, L. Cortorreal agreed to not “prepare or transmit income tax returns or offer financial products except in his capacity as a Liberty franchisee.” Jd. 35. Additionally, L. Cortorreal agreed “he would not directly or indirectly solicit any person or entity served by any of his prior Liberty offices within the last twelve months that he [was] a Liberty franchisee for the purpose of offering income tax preparation or electronic filing of tax returns or financial products” for two years upon termination of the Franchise Agreements. /d. | 37. “L. Cortorreal also agreed under each of the Franchise Agreements not to do any act that is, in Liberty’s determination, harmful, prejudicial or injurious to Liberty .. . .” Jd. {38 (internal quotation and citation omitted). L. Cortorreal allegedly agreed that the Section 10 provisions are “reasonable, valid and not contrary to the public interest” and to “waive all defenses to the strict enforcement of Section 10.” Id. 39. Further, L. Cortorreal allegedly agreed that under Sections 9 and 10 of the Franchise

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